Critical access hospitals deserve EHR incentive dollars, not CMS gaffes

Pity the poor critical access hospital (CAH). These 25-or-fewer bed hospitals deal with a unique set of obstacles in caring for patients in their rural communities. They're less likely to have even the most basic electronic health record system. This is in large part why the Office of the National Coordinator for Health IT (ONC) announced last February that it would provide an additional $12 million in new technical support assistance through its regional extension centers to help CAHs and rural hospitals select and adopt EHRs. The intent of this supplemental funding was to provide additional technical support, primarily in the outpatient setting.  

So it's particularly disheartening to learn that the EHR incentive program is giving short shrift to eligible professionals treating outpatients at CAHs and billing pursuant to Medicare's physician fee schedule, either barring them outright, or paying them a smaller incentive bonus than the one to which they may be entitled. That's precisely what's happening, according to a Dec. 16 letter sent from the American Hospital Association (AHA) and the National Rural Hospital Association (NRHA) to Centers for Medicare & Medicaid Services Acting Administrator Marilyn Tavenner.

Under Medicare's payment methodology, these physicians bill for outpatient services. But depending on which forms they fill out, it can appear is if they are hospital-based, thus ineligible for EHR incentive payments.

CAHs often are the cornerstone for assuring access to care in their communities, Chantal Worzala, director of policy for the AHA in Washington, D.C., tells FierceEMR. She notes that more than a fourth of acute care hospitals in the United States have been designated as CAHs.

These providers aren't being dinged intentionally by the EHR incentive program; it's more of an oversight. "It's a brand new, large and challenging program, and this is a detail that CMS had not dealt with before," Worzala says. AHA first raised the issue with CMS in July; the Associations decided to send a letter when it appeared CMS was not addressing the technicality.  

The AHA has yet to hear from CMS since sending the letter, but Worzala is confident CMS will consider the merits of the program and "likely" will correct it.

Worzala also notes that CMS has done a "tremendous" job in rolling out the EHR incentive program, especially in a short timeframe. But inevitably issues will crop up, particularly for CAHs. For instance, there may be issues as to how incentive payments for CAHs will be determined based on allowable acquisition costs, not the prospective payment law, and the fact that many CAHs don't have sufficient broadband to support the use of EHRs.  

These rural hospitals are called "critical access" for a reason. CMS needs to address technicalities such as this one in a timely manner: Physicians who are serving patients in these often isolated communities deserve no less. - Marla

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